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Implementation Guidelines for RBI Master Direction on IT Governance, Risk, Controls and Assurance Practices.

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Contents

The RBI Master Direction aims to enhance the IT governance, risk management, controls, and assurance practices of regulated entities (REs). The Master Direction consolidates and updates previous guidelines on IT governance, risk, controls, assurance practices, and business continuity/disaster recovery management. It applies to scheduled commercial banks (excluding regional rural banks), small finance banks, payments banks, non-banking financial companies, credit information companies, and all India financial institutions.  The Master Direction comes into effect from 1 April 2024 and is applicable to following entities:

  • All Banking Companies, including those incorporated outside India and licenced to operate in India (‘Foreign Banks’), Small Finance Banks (SFBs), and Payments Banks (PBs).
  • Non-Banking Financial Companies (NBFCs) classified as ‘Top Layer’, ‘Upper Layer’ and ‘Middle Layer’.
  • Credit Information Companies (CICs).
  • All India Financial Institutions (AIFIs), such as EXIM Bank, NABARD, NaBFID, NHB, and SIDBI

Key aspects of the Master Direction include:

  • Establishing a robust IT governance framework with a clear governance structure and processes.
  • Defining the roles and responsibilities of the Board of Directors, senior management, and the head of the IT function.
  • Implementing comprehensive information security and cyber security policies and frameworks.
  • Conducting regular risk assessments, vulnerability assessments, and penetration testing.
  • Putting in place effective business continuity and disaster recovery plans.
  • Establishing an independent IS audit function.

Complying with Master Direction involves sustained efforts. Regulated Entities can adopt a phased approach for conducting gap assessment and ensuring compliance with the RBI Master Direction.

A recommended process includes:

  • Gap Assessment: Conduct a thorough gap assessment to identify areas where existing practices fall short of the requirements outlined in the Master Direction.
  • Control Implementation: Develop and implement appropriate controls and processes to address the identified gaps.
  • Re-assessment: Regularly re-assess the implemented controls and processes to ensure their effectiveness and make necessary adjustments.
  • Monitoring and Reporting: Establish mechanisms for monitoring compliance with the Master Direction and reporting relevant information to the Board and senior management.

Implementation Checklist for RBI Master Direction for IT

The following table provides a checklist of key implementation items along with detailed guidelines and relevant questions to aid in tracking progress.

Implementation Item Implementation Guidelines
Establish IT Strategy Committee (ITSC)
  • Minimum of three directors, with the Chairperson being an independent director with substantial IT expertise.
  • Members should be technically competent.
  • ITSC should meet at least quarterly.
  • Ensure alignment of IT Strategy with the overall business strategy.
Define Roles and Responsibilities
  • Clearly define roles and responsibilities of the Board, Senior Management, Head of IT Function, and CISO.
  • Document the roles and responsibilities in relevant policies and procedures.
Develop Information Security and Cyber Security Policies
  • Develop comprehensive Information Security and Cyber Security Policies covering all aspects of IT security and risk management.
  • Establish an Information Security Committee (ISC) to oversee information/cyber security.
  • Designate a CISO with the requisite technical expertise and experience.
Conduct Risk Assessment
  • Conduct regular risk assessments of all information assets and systems.
  • Use appropriate risk assessment methodologies and tools.
  • Document the findings of the risk assessments.
Implement Vulnerability Assessment and Penetration Testing
  • Conduct VA at least once in every six months and PT at least once in 12 months for critical systems.
  • Use independent and qualified experts for VA/PT.
  • Remediate identified vulnerabilities in a timely manner.
Develop Business Continuity and Disaster Recovery Plan
  • Develop a comprehensive BCP and DRP that addresses all critical systems and business processes.Conduct regular DR drills to test the effectiveness of the plan.
  • Review and update the plan regularly based on changing business requirements and risk assessments.
Establish IS Audit Function
  • Establish a separate IS Audit function or allocate dedicated resources within the internal audit function.
  • Develop an IS Audit Policy that defines the mandate, scope, and responsibilities of the function.
  • Conduct regular IS audits of critical systems and processes.

Note: It is important to note that this checklist is not exhaustive, and organisations should refer to the complete RBI Master Direction for detailed requirements or reach out to CyberNX for detailed discussion on compliance requirements.

CyberNX can assist Regulated Entities (REs) in conducting comprehensive gap assessments and achieving compliance with RBI Master Directions. Our services include implementing controls and automating compliance processes, creating dashboards, generating detailed reports, and more. Contact us today to streamline your RBI Master Direction compliance journey.

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